If you believe that a violation of a law or regulation has occurred or will occur in your

workplace or elsewhere in the organisation, we encourage you to report your knowledge or

concerns.

You can make the report to your direct superior or the management.

You are also welcome to use our whistleblower system.

You can use the whistleblower system to report any type of breach of the law, such as fraud,

corruption, insider trading, discrimination, (sexual) harassment, serious breaches of IT

security and other serious matters. The report will be received and processed by an external

law firm and full confidentiality is guaranteed. You can choose to remain completely

anonymous. All reports are welcome.

One reason for setting up a whistleblower system is that it is legally required. Once the Whistleblower Protection Act, which is currently in the final legislative phase, comes into

force, all organisations with more than 249 employees will be obliged to set up an internal reporting channel.

The obligation will only apply to smaller organisations with more than 49 employees but no more than 249 employees from 17.12.2023.

In our view, however, better reasons lie in the establishment of a culture of speaking up and in

the fact that a whistleblower system is or should become an important part of the organisation's compliance management system.

The establishment of the LockLine “whistleblower system with ombudsperson”, offered by

us, provides an internal reporting channel and thus fulfils the legal obligations under the

Whistleblower Act.

However, our LockLine whistleblower system with ombudsperson can do much more, and its

objective is more far-reaching.

The aim is to reliably prevent and/or detect violations through reports, as these can lead to

considerable financial disadvantages for your organisation and reputational damage.

Our aim is therefore not just to formally fulfil the legal requirements, but to establish a truly

functioning and effective whistleblowing system.

The special appeal of an internal reporting channel also includes the option of submitting anonymous

reports. An anonymous whistleblower feels safer and will disclose misconduct more readily and

easily than one who is obliged to disclose their name. Our LockLine whistleblower system with

ombudsperson enables anonymous reporting. Even if the name is disclosed, the whistleblower is free

to decide whether or not it is passed on to the organisation. The whistleblower's decision to remain

anonymous is safeguarded by the ombudsperson, with their professional duty of confidentiality.

Right from the start, the whistleblower is in a very safe environment, our “LockLine”, something

which makes our ombudsperson-backed whistleblower system particularly attractive and encourages

the whistleblower.

The attractiveness of an internal whistleblowing channel is decisively determined by the level of

confidentiality applied to the information and what consequences a report will have. If the internal

reporting channel is set up within the organisation itself, there is a regular risk of conflicts of interest.

The whistleblower might not disclose if they have doubts about the confidentiality and seriousness

with which their tip will be treated. The solution of bringing in an external person of trust largely

rules out conflicts of interest. It also ensures compliance with the legally prescribed processes and

the daily functioning of the reporting channel, which would have to be safeguarded by deputisation

rules in the event of the responsible person being on holiday or sick.

The whistleblowing hotline will work effectively and achieve its objectives if the installation,

working methods and compliance with confidentiality are well communicated within the

organisation. We will provide you with our communication package for this purpose.

It is also important to communicate potential follow-up measures.

An annual evaluation must be carried out to check whether the whistleblowing hotline is

working and/or whether it needs to be improved and adapted.

In principle, you can always submit a report if you have the feeling that something is not

going according to the rules. The whistleblower hotline can therefore be used, for example, to report:

• Violations of guidelines

• Human rights risks or violations

• Environmental risks or injuries

• Conflicts of interest

• Corruption

• Fraud

• Theft

• Insider trading

• Inappropriate gifts and hospitality

• Breaches of confidentiality

• Bribery and payoffs

• Inappropriate customer billing

• Inappropriate reporting of expenses

• Violations against data protection

• Harassment

• Discrimination

• Falsification of official documents

• Disregard for occupational health and safety and work-related health hazards